Privacy Policy

We at Close To My Heart, Inc., and its Canadian subsidiary, Close To My Heart Canada Ltd. (”Close To My Heart”), are committed to high standards of customer information management and security. We do not sell, rent or trade your personal information to others. We require the same high standards of our independent Close To My Heart Consultants who sell our products to customers throughout the United States and Canada. This Close To My Heart Privacy Policy explains how we obtain, use and protect customer information.

Your Consent

The foundation of our privacy policy is your consent. The basic rule of this privacy policy is to only collect, use or disclose your personal information in ways and for purposes you consent to, or purposes that a reasonable person would consider appropriate in the circumstances.

Our consent may be implied or express, depending on context, and depending on the nature and sensitivity of the information. Your consent might be reasonably implied where our purpose for collecting, using or disclosing your personal information would be considered obvious and you voluntarily provide your personal information for that obvious purpose.

You may withdraw your consent for Close To My Heart to retain, use or disclose your personal information at any time by giving us reasonable notice in writing, except where there exists a legitimate law enforcement purpose, or a bona fide legal dispute involving the parties.

How We Obtain Your Personal Information

Close To My Heart obtains your personal information (such as name, home address, e-mail address, telephone number, date of birth and product preferences) either from the independent Close To My Heart (“CTMH”) Consultants who sell our products to the public, or from you directly. We do not purchase lists of prospective customers. We may obtain your personal information from CTMH Consultants in one of two ways: when they submit product orders to us and when they enter your name and address into a customer database maintained by us for use by CTMH Consultants. See the next section for information about how your personal information in the customer database is used. We obtain your personal information directly from you when you request a referral to a CTMH Consultant, or if you enter an order in any online order function we may have on our Web sites in the future.

How We Use Your Personal Information

Your personal information is stored in a secure, limited-access electronic database and in limited-access physical files. It is used to fulfill and ship your product orders and to enhance customer service. The “customer service” uses of your personal information are limited to:

reporting and search functions made available only to the CTMH Consultant who entered it,

access by trained Close To My Heart customer service personnel on a limited-access, as-needed basis, and

use by Close To My Heart for occasional mailings or promotions.

Information you provide may be aggregated or made generic by stripping it of personally-identifying characteristics for reporting purposes and made available to other CTMH Consultants, CTMH employees and third parties.

Who We Allow Access to Your Personal Information

We do not sell, rent or trade your personal information to others. We only disclose or make available your personal information to third parties strictly as follows:

to the CTMH Consultant who provided it or entered it into our database;

to Close To My Heart employees, on a controlled, as-needed basis, and only subject to strict covenants of non-disclosure and non-use;

to shippers for the limited purpose of shipping orders, and subject to covenants of confidentiality;

to trusted, professional information technology contractors developing computer software, and only subject to strict covenants of non-disclosure and non-use;

if you specifically request a referral to a CTMH Consultant, to a limited number of CTMH Consultants in geographical proximity to you;

subject to court order;

subject to legitimate law enforcement purposes; and

to our lawyers in the event of a legal dispute.

How We Keep Your Personal Information Secure

We take data security very seriously. Among the measures in place to protect the security of personal information are the following:

encrypted data transfer;

encryption at the database level;

restricted access to only those individuals having a legitimate business purpose to access information, consistent with your consent (express or implied) and reasonable expectations; and

alarms and locks to restrict and control physical access.

Despite taking commercially-reasonable security measures, we cannot absolutely prevent all unintended disclosure or use of personal information, and thus we will not be liable for security breaches which are neither intentional nor negligent.

Who You Can Contact About Our Privacy Policy and Your Personal Information

Inquiries or complaints concerning Close To My Heart’s privacy policy and practices or your personal information may be directed to the Close To My Heart privacy officer as follows:

Sheena Searls

Privacy Officer

Close To My Heart

1199 West 700 South
Pleasant Grove, UT 84062 USA

Effective Date and Changes to this Privacy Policy

The Close To My Heart privacy policy came into effect February 23, 2005. We may amend this policy from time to time. Read the Close To My Heart privacy policy from time to time to be apprised of any changes.

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